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Follow-Up Report:

EPA Improves Management 

of Its Radiation 

Monitoring System

Report No. 14-P-0321 July 22, 2014

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL
Report Contributors: Eric Lewis

Dwayne Crawford

Christine Baughman

Andre von Hoyer II

Rodney Rice

Abbreviations

EPA U.S. Environmental Protection Agency

MATS Management Audit Tracking System

NAREL National Analytical Radiation Environmental Laboratory

OAR Office of Air and Radiation

OARM Office of Administration and Resources Management

OIG Office of Inspector General

RadNet Radiation monitoring system

Cover photo: A stationary air monitor located in Montgomery, Alabama. (EPA OIG photo)

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This is one of the U.S. Environmental Protection Agency Office of Inspector General’s 

products associated with issues related to the EPA’s radiation monitoring system. For details 

on related reports, go to:

http://www.epa.gov/oig/reports/2012/20120419-12-P-0417.pdf

http://www.epa.gov/oig/reports/2009/20090127-09-P-0087_glance.pdf

http://www.epa.gov/oig/reports/2006/20060426-2006-P-00022_glance.pdf
 

 14-P-0321

July 22, 2014

Why We Did This Review

We performed this follow-up 

review to assess actions taken by 

the U.S. Environmental Protection 

Agency (EPA) to address the

recommendations in the Office of 

Inspector General (OIG) Report 

No. 12-P-0417, Weaknesses in 

EPA’s Management of the 

Radiation Network System 

Demand Attention, issued April 19, 

2012. Our work focused on 

actions that the EPA said were 

completed as of January 10, 2014. 

Specifically, the EPA reported that 

it had completed seven of the 

eight OIG recommendations from 

our 2012 report.

The EPA’s nationwide radiation 

monitoring system (RadNet) is 

designed to measure ambient 

levels of radiation in the 

environment and large-scale 

atmospheric releases of radiation.

The RadNet includes, among 

other things, a network of 

stationary air monitors that send 

near-real-time measurements of 

radiation to an EPA national 

laboratory. 

This report addresses the 

following EPA goal or 

cross-agency strategy:

 Addressing climate change 

and improving air quality.

For further information, 

contact our public affairs office 

at (202) 566-2391.

The full report is at:

www.epa.gov/oig/reports/2014/ 

20140722-14-P-0321.pdf

 

Follow-Up Report: EPA Improves Management 

of Its Radiation Monitoring System

 What We Found

Responsible EPA offices completed corrective 

actions on all seven recommendations we 

reviewed. As a result of the completed corrective 

actions to date, the stationary air-monitoring 

network increased in both coverage and 

effectiveness. 

Through its actions, the EPA increased the number of air monitors installed 

from 124 to 132, and the agency has eight additional monitors available for 

installation. Based on recent weekly status reports, an average of 

92.9 percent of installed monitors are operating. This is an improvement from 

the 80 percent of installed monitors operating in March 2011. 

As of the date we started our review, not all of the corrective actions 

completed by the EPA were recorded in its official system for tracking 

corrective actions. However, as of April 22, 2014, the EPA completed all 

required actions and properly entered the data into its official tracking system.

We were told that the completion of corrective actions for the remaining 

recommendation (recommendation 8), involving the tracking of the installation 

of RadNet monitors, is scheduled for September 2014.

EPA officials reviewed a draft of this report and informed the OIG that they 

had no issues with the findings and thus no comments.

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

RadNet improvements 

have increased the 

EPA’s ability to assess 

radioactive threats to

the public and the 

environment.
July 22, 2014

MEMORANDUM

SUBJECT: Follow-Up Report: EPA Improves Management of Its Radiation Monitoring System

Report No. 14-P-0321

FROM: Arthur A. Elkins Jr.

TO: Janet McCabe, Acting Assistant Administrator

Office of Air and Radiation

Craig E. Hooks, Assistant Administrator

Office of Administration and Resources Management

This is our report on the subject review conducted by the Office of Inspector General (OIG) of the 

U.S. Environmental Protection Agency (EPA). This report contains findings that describe the problems 

the OIG has identified and corrective actions taken by the EPA. This report represents the opinion of the 

OIG and does not necessarily represent the final EPA position. However, EPA officials reviewed a draft 

of this report and informed the OIG that they had no issues with the findings and thus no comments.

Because this report contains no recommendations, you are not required to respond to this report and it 

will be closed upon issuance. However, if you submit a response, it will be posted on the OIG’s public 

website, along with our memorandum commenting on your response. Your response should be provided 

as an Adobe PDF file that complies with the accessibility requirements of Section 508 of the 

Rehabilitation Act of 1973, as amended. The final response should not contain data that you do not want 

to be released to the public; if your response contains such data, you should identify the data for 

redaction or removal along with corresponding justification.

We will post this report to our website at http://www.epa.gov/oig. 

THE INSPECTOR GENERAL

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460
Follow-Up Report: EPA Improves 14-P-0321

Management of Its Radiation Monitoring System

Table of Contents

Purpose ..................................................................................................................... 1

Background .............................................................................................................. 1

Scope and Methodology........................................................................................... 3

Results of Review ..................................................................................................... 3

Corrective Actions Are Now Completed and Recorded in the

 Official Agency Tracking System ....................................................................... 3

EPA Actions on OIG Recommendations Resulted in Expanded 

 and Increased RadNet Operational Readiness ................................................. 5

Conclusion ................................................................................................................ 6

Agency Response and OIG Evaluation.................................................................... 6

Appendix

A Distribution ...................................................................................................... 7
14-P-0321 1

Purpose

We reviewed actions taken by the U.S. Environmental Protection Agency (EPA) 

to address the recommendations in the Office of Inspector General (OIG) Report 

No. 12-P-0417, Weaknesses in EPA’s Management of the Radiation Network 

System Demand Attention, issued April 19, 2012. We reviewed the status of the 

corrective actions for seven recommendations for which corrective actions were 

listed as completed in the EPA’s Management Audit Tracking System (MATS) as 

of January 10, 2014. The Assistant Administrator for the Office of Air and 

Radiation (OAR) and the Assistant Administrator for the Office of Administration 

and Resources Management (OARM) were the action officials for these 

recommendations. 

Background

The EPA’s nationwide radiation monitoring system (RadNet) is designed to 

measure ambient levels of radiation in the environment. The RadNet also 

measures large-scale atmospheric releases of radiation impacting large parts of the 

country and major population centers due to: large nuclear facility incidents or 

accidents, large foreign radiological incidents or accidents, radiological dispersion 

devices resulting in widely impacted areas (e.g., multi-county or larger), and 

nuclear weapon detonations. The RadNet regularly samples the nation’s air, 

precipitation, drinking water and pasteurized milk for a variety of radionuclides 

and radiation types.

The RadNet system is managed by the National Analytical Radiation 

Environmental Laboratory (NAREL). The NAREL is part of the EPA’s Office of 

Radiation and Indoor Air, which is within the OAR. According to its website, the

NAREL is a comprehensive environmental laboratory committed to developing 

and applying the most advanced methods for measuring environmental 

radioactivity and evaluating the risk to the public.

This report, like its April 2012 predecessor, addresses the air-monitoring portion 

of the RadNet. To sample the air, the NAREL established a network that currently 

has 132 stationary air monitors. The EPA’s December 2004 “Critical 

Infrastructure and Key Resources Protection Plan” identified the RadNet monitors 

as critical infrastructure. Air monitors are located in the District of Columbia, 

Puerto Rico, and every state except South Carolina. Some states have more than 

one monitor. Figure 1 shows the locations of these monitors. Every hour each 

stationary monitor sends near-real-time measurements of beta and gamma 

radiation to the NAREL. Filters on the air monitors capture particles from the air 

(airborne particulates). Monitor operators collect the filters and send them to the

NAREL for testing.
14-P-0321 2

The EPA OIG’s April 2012 audit report sought to determine whether the agency

effectively implemented corrective actions to address the findings and 

recommendations from the previous EPA OIG Report No. 09-P-0087, EPA Plans 

for Managing Counter Terrorism/Emergency Response Equipment and Protecting 

Critical Assets Not Fully Implemented, issued January 27, 2009. The EPA OIG’s 

April 2012 report found that broken RadNet monitors and delayed filter changes 

impaired this critical infrastructure asset. 

The EPA’s management of the RadNet as a low priority, parts shortages, and 

insufficient contract oversight contributed to extensive delays fixing broken 

monitors. On March 11, 2011, at the time of the Fukushima, Japan, nuclear 

incident, 25 of the 124 RadNet monitors installed (20 percent) were out of service 

an average of 130 days. The service contractor completed repairs on all monitors 

by April 8, 2011. In addition, broken RadNet monitors and relaxed quality 

controls led to untimely filter changes. Six of the 12 RadNet monitors that the

OIG sampled for its 2012 report had gone over 8 weeks in a 1-year period without 

a filter change. This is significant since out-of-service monitors and unchanged 

filters may reduce the quality and availability of critical data needed to assess 

radioactive threats to the public and the environment. 

According to EPA Manual 2750, Audit Management Procedures, EPA staff 

(i.e., the responsible office audit follow-up coordinator) tracks agency progress on 

the corrective actions resulting from OIG recommendations and updates the 

agency’s official audit-tracking system, or MATS, accordingly. When the 

responsible EPA action official completes corrective actions, the action official 

prepares a certification memorandum certifying that the actions were completed. 

Based on the certification memorandum, the audit follow-up coordinator from the 

responsible office enters the final action date in the MATS.

Figure 1: Map showing the current location of RadNet air monitors

Source: OIG analysis based on monitor locations provided by NAREL staff.
14-P-0321 3

Scope and Methodology

We performed our review from January through June 2014. We conducted this 

performance audit in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on our audit 

objectives.

We interviewed EPA staff in the NAREL, OAR and OARM’s Office of 

Acquisition Management who were involved in implementing corrective actions

for the seven recommendations we reviewed. We also reviewed various guidance 

documents, including EPA Manual 2750. In addition, we visited the NAREL in 

Montgomery, Alabama, to observe air monitors and other facility operations.

We did not review corrective actions for one recommendation (recommendation 8) 

made in the EPA OIG’s April 2012 report because the corrective actions were not 

completed when we started our review. This recommendation involved tracking the 

installation of RadNet monitors against a revised schedule. We were told in 

May 2014 by the OAR Audit Follow-Up Coordinator that the completion of 

corrective actions for recommendation 8 is scheduled for September 2014. 

Results of Review

The OAR and the OARM completed and recorded corrective actions on seven 

recommendations made in the EPA OIG’s April 2012 report. Through these 

actions, the EPA increased the number of the RadNet fixed air monitors installed, 

which expanded system coverage. These actions also increased the RadNet 

system’s operational readiness. 

Corrective Actions Are Now Completed and Recorded in the 

Official Agency Tracking System

Both the OAR and OARM completed corrective actions for the seven 

recommendations we reviewed, as summarized in table 1. Not all of the actions 

were reflected in the MATS as of January 10, 2014. However, during the course 

of our follow-up review EPA staff revised the MATS to include the most recent 

actions.

With two exceptions, as of January 10, 2014, the MATS properly reflected the 

corrective actions taken at that time. As shown in table 1, the MATS was not 

current for actions taken on OIG recommendations 3 and 7. Regarding 

recommendation 3, the MATS did not reflect that the NAREL established a 

metric of 200 hours for changing the filters in the air monitors. To prevent blower 

motor damage, the RadNet air monitors are typically programmed to stop after 
14-P-0321 4

200 hours of operation should the blower not be able to maintain air flow. 

Maintaining a set flow rate during sampling is a desirable operating goal. If a set 

air flow is not maintained, less material is collected during the sampling interval. 

Air flow issues may adversely affect the collection efficiency of the filter. At our 

request, the NAREL documented the 200-hour limit in a quality assurance project 

plan for the RadNet. Staff from the OAR revised the MATS in April 2014 to 

reflect the 200-hour limit.

Regarding recommendation 7, the MATS incorrectly identified May 2012 as 

the date for the performance evaluation of delivery order three under contract 

EP-W-07-076. The OARM certification that this recommendation was complete 

was also incorrect, since the April 2013 date it cited was for an evaluation that 

was withdrawn shortly afterwards. The correct date for completing the 

performance evaluation of delivery order three is April 2014. Staff from the

OARM revised the MATS in April 2014 to reflect recent corrective actions.

Table 1: Summary of actions completed and reported

Recommendation

Did the action officials 

complete appropriate

corrective actions?

Were corrective actions 

properly reported in 

MATS?

1. Establish and enforce written 

expectations for RadNet operational 

readiness commensurate with its role in 

and importance to EPA’s mission. 

Yes Yes

2. Implement metrics for RadNet operational 

readiness to be reviewed daily by NAREL, 

and periodically by OAR (at least monthly) 

and by the Deputy Administrator (as 

needed).

Yes Yes

3. Direct that NAREL improve planning and 

management for RadNet.

Yes No

4. Require follow-on RadNet contracts to 

include incentives/disincentives and a 

requirement for monthly progress reports.

Yes Yes

5. Require the contracting officer and 

contracting officer representative to 

formally evaluate RadNet contractors’ 

performance on an annual basis and 

enter information into Past Performance 

Information Retrieval System through 

Contractor Performance Assessment 

Reporting System. 

Yes Yes

6. Determine whether domestic contract 

options are available for crucial repair 

parts that are identified as only being 

available from a foreign subcontractor. 

Yes Yes

7. Review the information in MATS for the 

prior audit and ensure it is accurate and 

current. 

Yes No

Source: OIG analysis.
14-P-0321 5

EPA Actions on OIG Recommendations Resulted in Expanded and 

Increased RadNet Operational Readiness

Corrective actions taken by the EPA in response to our recommendations have 

increased the availability of critical data needed to assess radioactive threats to the 

public and the environment. There are more air monitors in the network now and 

a greater percentage of the total monitors are operating properly. Table 2 

compares some key operational factors from the prior report to the current 

situation.

Table 2: Comparison of RadNet operational factors before and after corrective actions

Operational factor

EPA OIG

April 2012 report

After corrective actions on

2012 recommendations

Number of stationary air 

monitors in RadNet.

124 monitors 132 monitors

Percent of stationary monitors 

operating (i.e., operational 

readiness).

80%

(on 3/11/2011)

92.9%

(average of weekly reports for a 

73-week period)

Number of stationary monitors 

not operating for at least 

14 days.

24 monitors

(on 3/11/2011)

4.1 monitors

(average of weekly reports for a 

73-week period)

For 12 randomly selected 

stationary monitors, number of 

filters analyzed during a 1-year 

period.

728

(5/1/2010 – 4/30/2011)

929

(1/1/2013 – 12/31/2013)

For 12 randomly selected 

stationary monitors, longest 

number of days between filter 

changes.

339 days

(5/1/2010 – 4/30/2011)

46 days

(1/1/2013 – 12/31/2013)

Source: OIG analysis.

Since the EPA OIG’s April 2012 report, there are a larger number of installed 

monitors in the network—132 monitors instead of 124. In addition, the NAREL 

has eight more air monitors available for installation, which will bring the 

network total up to 140 monitors. Locations in Paducah, Kentucky, and 

Columbia, South Carolina, have been selected for two of the eight additional 

monitors; the locations for the other six have not yet been decided.

Furthermore, the NAREL has increased the RadNet’s operational readiness. Our 

analysis of weekly status reports provided by the NAREL covering a 73-week 

period ending with the week of February 17, 2014, showed that an average of 

92.9 percent of the air monitors were operational, up from 80 percent in 

March 2011. For selected monitors over a 1-year period, the length of time that 

individual monitors were not operating had been reduced, as evidenced by the 

reduction in the longest number of days between filter changes. Similarly, the 

operators sent more air filters from these monitors to be analyzed by the NAREL.
14-P-0321 6

Conclusion

The OAR and the OARM completed corrective actions on the recommendations 

reviewed from EPA OIG Report No. 12-P-0417, and have now properly recorded 

their efforts in the MATS. As a result of these efforts, the stationary airmonitoring network increased its coverage and effectiveness. In addition, 

completing the corrective actions increased the EPA’s ability to assess radioactive 

threats to the public and the environment.

Agency Response and OIG Evaluation

On June 24, 2014, the OAR and OARM responded that they appreciated the 

OIG’s efforts to assess whether the EPA is successfully addressing the 

recommendations in the OIG Report No. 12-P-0417 issued in April 2012. The 

OAR and OARM stated that they reviewed the draft report and had no further 

comment. Since the OAR and OARM completed corrective actions on the 

recommendations we reviewed and have now properly recorded their efforts in 

MATS, this final report is closed upon issuance.
14-P-0321 7

Appendix A

Distribution

Office of the Administrator

Assistant Administrator for Air and Radiation

Assistant Administrator for Administration and Resources Management

Agency Follow-Up Official (the CFO)

Agency Follow-Up Coordinator

General Counsel

Associate Administrator for Congressional and Intergovernmental Relations

Associate Administrator for External Affairs and Environmental Education

Deputy Assistant Administrator for Air and Radiation

Principal Deputy Assistant Administrator for Administration and Resources Management

Director, Office of Radiation and Indoor Air, Office of Air and Radiation

Director, National Analytical Radiation Environmental Laboratory, Office of Air and Radiation

Director, Office of Acquisition Management, Office of Administration and 

Resources Management

Director, Office of Policy and Resource Management, Office of Administration and

Resources Management

Deputy Director, Office of Policy and Resource Management, Office of Administration and

Resources Management

Director, Office of Regional Operations

Audit Follow-Up Coordinator, Office of Air and Radiation 

Audit Follow-Up Coordinator, Office of Administration and Resources Management

Audit Follow-Up Coordinator, Office of Acquisition Management, Office of Administration and 

Resources Management